2012 (11) TMI 101

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..... 3. Rival contentions have been heard and record perused. From record we find that the assessee is engaged in the business of ginning and pressing of cotton. During the course of scrutiny assessment, the Assessing Officer found that the method of valuation of closing stock was changed from market price to cost or net realizable value whichever is lower which resulted into reduction of profit by Rs. 9,88,363, therefore, the Assessing Officer added the difference to the returned income. 3. By the impugned order, the Commissioner of Income Tax (Appeals) deleted the addition after having the following observations :- "4.1 Ground no. 1 is against the addition of Rs.9,88,363/- on account of undervaluation of closing stock. Copies of sub....

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....ssessment order that appellant's above submission is not justifiable as it could not fully convince the reason for deviation in method of valuation of closing stock. The appellant having given such a cogent explanation supported by relevant details, it was for the A.O. to specifically state as to what was wanting in the appellants explanation and while it was not justified or as to how it could not fully convince the A.O. with the reason for deviation in the method of valuation of closing stock. For this reason, the A.O.'s order and finding in the matter is nonspeaking. Alongwith voluminous details filed by the ld. AR, copy of my predecessor's order dated 13.02.2004 in Appeal No. IT-121/03- 04/474 in the case of M/s Satyam Cotex P(Ltd.), a ....